Extension to Entities Filing Partnership Returns, Etc.

ID: CCA_2012081614143237
Office: ---
UILC: 6233.00-00
From: ---
Sent: Thursday, August 16, 2012 2:15:04 PM
Number: 201247014
Release Date: 11/23/2012
To: ---
Cc: ---
Subject: RE: TMP and REIT ---
My mistake. I confused the term REMIC and REIT. But TEFRA would apply in any event if a partnership return was filed pursuant to section 6233 and Treas. Reg. 301.6233-1(a) if the small partnership exception does not apply. Trusts can elect to be taxed as partnerships under the check-the-box regulations. Whether this option exists for REITS would be under PSI jurisdiction. ---is the expert on check-the-box. PSI also has jurisdiction over trusts which presumably includes trusts that are REITs.